Macondo Well Deepwater Horizon Blowout Lessons for Improving Offshore Drilling Safety (2012) / Chapter Skim
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6 Regulatory Reform
6 Regulatory Reform
Pages 111-127
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From page 111... ...
The bureau eventually named the Bureau of Ocean Energy Management, Regulation, and Enforcement was assigned responsibility for regulating the safety of offshore drilling operations.
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From page 112... ...
The net effect of these decisions made by the rig personnel was to reduce the available margins of safety that take into account complexities of the hydrocarbon reservoirs and well geology discovered through drilling and the subsequent changes in the execution of the well plan. Critical aspects of drilling operations were left to industry to de 3 A general discussion of federal regulation of offshore drilling in the United States with a focus on regulatory oversight of deepwater drilling in the Gulf of Mexico is provided by Presidential Commission (2011)
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From page 113... ...
. The National Commission on the BP Deepwater Horizon Oil Spill and Offshore Drilling found that MMS regulations were inadequate to address the risks of deepwater drilling and did not assess the full set of risks presented by the temporary abandonment procedure used at the Macondo well.
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From page 114... ...
waters. The following are advantages of goal-setting risk management systems over prescriptive regulatory systems: Putting the focus on achieving clearly stated health, safety, and environmental objectives; Requiring operators, drilling contractors, and service companies to document their approach to safety, in contrast to basing safety on compliance with prescriptive regulations; Requiring operators, drilling contractors, and service companies to work together to meet safety objectives; Formalizing and documenting the risk management procedures and responsibilities of all parties; Providing a context for effective communication on health, safety, and environmental issues as they arise; Providing for checks and balances for well planning and operations, especially with regard to management of change;
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From page 115... ...
offshore oil and gas industry. Encourage the development and integration of a strong safety culture and safety management systems among operating companies (and joint venture partner companies)
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From page 116... ...
For example, both in U.S. waters and abroad, several of the operating companies are using shore-based real-time operations centers to monitor offshore drilling operations continuously, although there is no explicit requirement to do so.
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If it determines that the company does not have sufficient expertise to carry out the proposed drilling plan, PSA withholds consent for an operator's plan. Drilling operations are not allowed to proceed until PSA consents.
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From page 118... ...
API and the International Association of Drilling Contractors are developing a Well Construction Interface Document that could be a model for such a bridging document. Several advantages of using a bridging document as part of a goal-oriented risk management system are that it could help Unify the risk management systems of the operator, drilling contractor, and service companies in a way that clearly defines the roles and responsibilities of all parties for health, safety, and environmental protection; Provide detailed project-specific information to be shared by key personnel regardless of whether they are employed by the operator, the drilling contractor, or a service company; and Facilitate the management of change process and serve as a mechanism to communicate the implications of program changes to all key personnel.
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From page 119... ...
This could occur, for example when the difference between the equivalent circulating density and the fracture gradient is not greater than a predefined minimum value either during drilling or cementing. Offshore drilling operations will face increasing complexity as they move into ever-greater water depths and more challenging environments.
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From page 120... ...
The use of SEMS will require increased competence of everyone involved in offshore drilling operations -- from the engineers developing technical plans and the workers and technicians carrying them out to the regulators overseeing such operations. As discussed in Chapter 5, there is a need for a better-educated and better-trained work force in the United States to avoid catastrophic system failures and meet the challenges of the future.
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From page 121... ...
This center has the potential to engage the CEOs of oil and gas companies, drilling contractors, and service companies in risk management; set standards for training and certification; develop accreditation systems for industry training programs; and facilitate industry participation in safety audits and inspections. Ideally, the center should represent a collaboration of industry and government.
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From page 122... ...
Recommendation 6.11: The manner in which the above-mentioned codes and standards will be enforced should be specified by BSEE in the well plan submitted by operating companies for approval. Recommendation 6.12: BSEE should adopt a system of precertification of operators, contractors, and service companies before granting a drilling permit for especially challenging projects.
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From page 123... ...
Offshore drilling operations are currently governed by a number of agencies with complementary and in some cases overlapping areas of statutory responsibility. Table 6-1 lists a number of the principal agencies that have jurisdiction over regulating various potential hazards related to offshore drilling.
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From page 124... ...
EPA, BOEMRE, USCG Explosion FS, BOEMRE, USCG Events from adjacent installations BOEMRE Epidemic or pandemic CDC, USCG Fire FS, BOEMRE, USCG Diving operations BOEMRE, USCG Dropped objects FS, BOEMRE, USCG Helicopter crash FAA, USCG Loss of stability FS, USCG Major mechanical failure FS, USCG Mooring or station keeping failure FS, BOEMRE, USCG Seismic activity FS, BOEMRE, USCG Ship collision FS, USCG Structural failure FS, BOEMRE, USCG Toxic release EPA, FAA, FS, BOEMRE, USCG Weather and storms FS, BOEMRE, NOAA, USCG a Does not include possible jurisdiction to conduct an investigation following incident. Abbreviations: CDC, Centers for Disease Control and Prevention; EPA, Environmental Protection Agency; FAA, Federal Aviation Administration; FBI, Federal Bureau of Investigation; FS, Flag-State maritime authority; BOEMRE, Bureau of Ocean Energy Management, Regulation, and Enforcement; NOAA, National Oceanic and Atmospheric Administration; TSA, Transportation Security Administration; USCG, United States Coast Guard.
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From page 125... ...
BSEE should have purview over integrating regulation, inspection, and monitoring enforcement for all aspects of system safety for offshore drilling operations. Recommendation 6.18: BSEE should work with other federal agencies to develop efficient and effective mechanisms for investigating future accidents and incidents.
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From page 126... ...
BSEE should strive to increase its technical competencies across the wide spectrum of expertise involved in offshore oil and gas exploration, including areas such as well design, cementing, BOPs, and remotely operated underwater vehicles. Safety Culture Summary Recommendation 6.25: BSEE and other regulators should foster an effective safety culture through consistent training, adher ence to principles of human factors, system safety, and continued measurement through leading indicators.10 10 As discussed in Chapter 5, leading indicators provide ongoing assurance that risks are being adequately controlled.
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From page 127... ...
127 Regulatory Reform Recommendation 6.26: As a regulator, BSEE should enhance its inter nal safety culture to provide a positive example to the drilling indus try through its own actions and the priorities it establishes.
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